Pine Environmental Services, LLC v. Carson

DISTRICT OF MASSACHUSETTS

TALWANI, District Judge.

I. Introduction

This case presents the issue of whether a laptop computer, previously used in interstate commerce, is a “protected computer” under the Computer Fraud and Abuse Act (“Act”), 18 U.S.C. § 1030, et seq., even when the laptop computer is not being used in interstate commerce. As set forth below, the court finds that such a laptop is not a “protected computer” under the Act, and that in the absence of this federal claim, the court lacks subject matter jurisdiction over Plaintiffs claims and Defendants’ counterclaims.

II. Background

Plaint…